On 14th September, the Isle of Man FSA published a news release saying that the Anti-Money Laundering and Countering the Financing of Terrorism (Amendment) Code 2018 came into effect on 14th September; and gives effect to recommendations made in the 2016 Mutual Evaluation Report issued by MONEYVAL following its 5th Round Mutual Evaluation of the Island. The main additions to the 2015 Code contained within the Amendment Code are:
- The introduction of requirements to establish, maintain and operate procedures in relation to sanctions screening;
- The introduction of the need to consider whether the relevant person has met the customer in the course of business when conducting business and customer risk assessments;
- The introduction of Paragraph 10A which places requirements on a relevant person to undertake certain considerations where an introducer is assisting with the customer due diligence process;
- Expansion of the requirements of Paragraph 21 to address recommended actions from MONEYVAL; and,
- Amendment of Paragraph 23 to ensure that it only deals with instances where a relevant person places reliance on an eligible introducer.